This is the key recommendation of the Institute’s Northern Ireland Tax Committee, chaired by Janette Burns, in its response last week to the UK Government consultation ‘Transfer pricing scope and documentation’. This consultation proposes to remove the medium sized transfer pricing exemption for cross-border transactions, which as the Committee has highlighted, will have a disproportionate impact in Northern Ireland for transactions with its nearest neighbour, Ireland. For that reason, the Committee recommends that the medium sized exemption remains for these transactions.
The Committee also recommended that there be a transition period of at least three years before removal of the medium sized exemption, if this proceeds. It also took the opportunity to highlight the need for the regional impact of policy changes to be embedded throughout the UK tax policy consultation and implementation cycle in future.